Abstract
On July 23, 2025, the International Court of Justice provided its Advisory Opinion on “The Obligations of States in Respect of Climate Change.” Requested by the UN General Assembly in 2023 (vide Resolution 77/276), the unanimous ruling is a landmark that will guide decision-making under International Law for decades to come as States cope with the impact's environmental degradation amidst rapidly warming temperatures. The Court characterized this growing crisis as “an existential problem of planetary proportions.” The Opinion for the first time makes clear that International Law addressed the entirety of the plant, and is a holistic body of treaty obligations and customary law duties. The Human Right to the environment girds these duties. A stringent duty of due diligence is required to fulfill theses substantive duties. While States will vary as they apply principles of law, including sustainable development, to observe their due diligence, none are exempt from doing their utmost to protect. Failures to do so have legal consequences under customary laws of State Responsibility. The Advisory Opinion applies to, and will guide decision-making under all multilateral environmental agreements (MEAs). To fulfill stringent due diligence, States are to implement national and international laws for environmental impact assessment (EIA), and other laws requiring use of Nature Based Solutions that protect biodiversity. The Opinion makes clear that States must discontinue reliance of fossil fuels. The Court's Opinion reflects the law set forth in the submissions of the International Union for the Conservation of Nature (IUCN). As States apply stringent due diligence, and national courts address legal claims regarding climate change, the Opinion will drive the progressive development of international climate law, from the lex lata expressed in the Opinion to the lex ferenda needed to protect all States and the planet.
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Introduction
Crises shape International Law. The rules that sovereign states observed governing their relationships before 1945 radically changed with the adoption of the United Nations (UN) Charter, and the end of imperial rule in colonies. Today's ongoing climate crisis, characterized accurately as “an existential problem of planetary proportions that imperils all forms of life and the very health of our planet,” 1 is similarly transformative. This crisis precipitates the emergence of new inter-national rules that guide state conduct. The UN General Assembly (UNGA) singularly recognized the legal dynamics of this crisis by requesting an Advisory Opinion on the climate crisis from the International Court of Justice (ICJ). 2
Humans have the knowledge and technologies to contain the climate crisis and adapt to changing living conditions. 3 Together, international law and national legal systems can, but do not yet, guide and mandate an end to the conduct that destroys the environment. Governments continue to cause and exacerbate the crisis, oblivious to imperiling civilization. 4 The ICJ alerts governments – and the fossil fuel industry – to the “legal consequences” 5 of their self-induced blindness. This Advisory Opinion in respect of Climate Change informs the UNGA, and the global community in all fields of endeavor, that actions imperiling the climate are unlawful. To respect International Law, state conduct will need to change, and will do so perhaps in unpredictable ways. Before examining four spheres of change that this Opinion inaugurates, it is useful to recall the context in which the UNGA made its request for an Advisory Opinion. 6
Clarifying the Integrity of International Law for Earth's Natural Systems
In its landmark Opinion given on July 23, 2025, the ICJ parsed international legal provisions regarding Earth's climate. The Court unanimously concluded by observing, that “International Law…has an important but ultimately limited role in resolving this problem. A complete solution to this daunting, and self-inflicted problem requires the contribution of all fields of human knowledge, whether law, science, economics or any other. Above all, a lasting and complete solution requires human will and wisdom - at the individual, social and political levels - to change our habits, comforts and current way of life in order to secure a future for ourselves and those yet to come.” 7
Before July 23, 2025, nations continuously debated when or how international law requires protecting the Earth's natural systems. They invoked legal uncertainty to justify deferring actions to safeguard the environment, whether about reducing reliance fossil fuels, or halting loss of natural habitats, or stopping their pollution of the oceans. Since environmental laws emerged in the 1970s, nations together have very rarely taken decisive, collective action to cease behavior harming the environment. When faced with reality that their use of chlorofluorocarbons (CFCs) had ruptured Earth's stratospheric ozone layer, nations ceased to manufacture and use of most ozone depleting substances. 8 They saved whales by suspending most hunting of great whales at sea. 9 Under most environmental agreements, however, States have agreed to make only modest changes, largely continuing business as usual. 10
Although most States acknowledged their duty to protect the environment, 11 they still embrace economic practices that incrementally harm Earth's natural systems. States gradually created the field of international environmental law, through negotiating treaties on many topics. 12 In 1987, the UN World Commission on Environment and Development documented the world's environmental crises in Our Common Future, calling for “sustainable” development and recommending the further elaboration of environmental laws. 13 States agreed to successive new environmental agreements, supported maturing work of the UN Environment Programme (UNEP), and the celebrated success of the 1992 Rio Earth Summit. 14 This cooperation led in 2015 to universal agreement for adopting the UN Sustainable Development Goals (SDGs). 15 Despite these advances, however, all nations today experience unprecedented, and worsening environmental degradation. 16 In diplomatic meetings, they still profess to be unsure about when or how their legal obligations require them to safeguard life on Earth. Protecting Earth has hardly been a security priority for most States.
According to the Intergovernmental Panel on Climate Change (IPCC), States are increasingly aware that they all alike depend upon Earth's “global system consisting of five major components: the atmosphere, the hydrosphere, the cryosphere, the lithosphere, and the biosphere, and the interactions between them.” 17 All States require Earth's natural systems to exist. They have taken nature for granted, at their peril. Since 1948, the International Union for the Conservation of Nature (IUCN), has been warning governments that their conduct is degrading nature jeopardies human wellbeing. 18 Extinction is irreversible.
Unsustainable Development Imperils life on Earth
Nations now experience conditions that no longer sustain their “habits, comforts and current way of life.” 19 An overwhelming body of evidence documents irreversible degradation of Earth's life-support systems: current reports from the United Nations Environment Program (UNEP), 20 the IPCC, 21 and the World Meteorological Organization (WMO), 22 and others such as the IUCN. 23 Biodiversity is in catastrophic decline and there is an 80 per cent likelihood that by 2030 Earth's ambient climate temperature will exceed the cap of 1.5°C, which nations pledged to honor in 2015. 24 Japan notes trends toward a 2°C increase temperature, in line with the Paris Agreement expectations, and approaching surface temperatures of 4°C by the 2100. 25 With these temperatures, there will be lethal heat and humidity, vast losses of flora and fauna, food shortages, collapse of marine ecosystems, forced migrations, and unpredictable “tipping” points radically altering habits for people and nature. 26 UN Secretary General António Guterres has called on nations to change course, remarking “We are playing Russian roulette with our planet. We need an exit ramp off the highway to climate hell, and the truth is we have control of the wheel.” 27
A legal road map to that exit ramp now exists. On July 23, 2025, the ICJ clarified the legal duties that oblige States to safeguard Earth's life-support systems. 28 States are duty bound to prevent significant harm to the environment, 29 and to cooperate for protection of the environment. 30 The Court ruled that all States are obligated to do their utmost to limit global warming to 1.5°C, and also to protect the oceans and biosphere, while respecting the human right to the environment. 31 States now begin a new, more intense debate: how and when to revise their national laws and policies to comply with their legal obligations.
Although national governments can no longer claim legal uncertainty as a basis for delaying a phase-out of fossil fuels use, ending pollution, or degrading habitats, will they nonetheless still continue to defer taking needed actions? Political pressure to do so domestically is mounting as climate-induced harms mount, in the wake of unprecedented floods and droughts, wildfires and sea level rise. As disasters occur, governments increasingly experience cause to regret not preparing for these impacts. 32 It is becoming politically expedient to address these climate change.
In 1992, US Secretary of State James Baker welcomed the UN Framework Convention on Climate Change (UNFCCC), endorsing such climate change measures via “a no-regrets policy.” 33 He urged a prudent approach of mitigating and adapting to climate change when doing so was already legally authorized, rather than waiting for the climate science to be definitive. Unfortunately, successive governments in the United States of America, and elsewhere, largely have ignored this approach, deferring their legal obligations under the UNFCCC. A generation has passed. In 2015, the UNGA unanimously adopted the 2030 Agenda for Sustainable Development, 34 and pledged to cap global warming at 1.5° by 2035. 35 It appears that the 1.5°C cap on global warming will have been exceeded, and the SDGs will not have been attained. States have squandered the time that was available to avert world-wide environmental harm. 36
Time-Lags Between Acknowledging A Duty and Acting
Before considering broadly how States can adhere to the legal norms set forth in the ICJ Advisory Opinion, it is instructive to recall how States have avoided taking decisive actions in their conferences of the parties for the UNFCCC and other multilateral environment agreements. States had agreed to clear duties in the UN Framework Convention on Climate Change in 1992, which entered into force in 1994. 37 Since then, States chose to take formal decisions by consensus, so that unless all States agreed, no decision could be taken. This precluded taking decisive action, even when the evidence justified doing so, and the UNFCCC rules are clear.
It is evident that States have been unwilling to act since doing so imperils their short-term economic benefits. States found that it was expedient to push difficult decisions off into the future. This pattern of behavior has been evident at least since 1992. Discounting the dangers, States with oil dependent economies proactively sought to defend their economies. To win agreement adopting Agenda 21 at the 1992 Earth Summit, every reference (but one 38 ) to the oil commodity was stricken from the text. No reforms to the petroleum economy were endorsed.
In order to bypass the consensus-driven inaction under the UNFCCC, France sought to rally agreement in the UN General Assembly on a new “Pact for the Environment.” States with economies invested in fossil fuels opposed negotiations on a proposed “Pact.” 39 They later supported convening the UNFCCC Conferences of the Parties for COP28 in Dubai and for COP29 in Baku, adroitly avoiding public pressure to take decisions to phase out use of fossil fuels. For a time, these States proactively also argued that international environmental law was too fragmented to provide a legal basis for requiring action about environmental problems. 40
Concerned at recurring failures address the gathering climate crisis, many jurists recommended that the UN General Assembly request an Advisory Opinion from the International Court of Justice. The UNGA's Rules of Procedure provide for formal voting (yes, no, abstain). 41 The precedent for such a resolution was the Advisory Opinion on nuclear weapons. 42 In a campaign that continued for five years, a coalition of young jurists persuaded Vanuatu to negotiate a draft resolution for adoption by the UNGA, requesting an Advisory Opinion on the International Law obligations of States in respect of Climate Change. 43 It took another two years for the Court to rule that States are obligated to do their utmost to protect Earth and prevent significant harm to the environment.
It is entirely likely that yet another generation will pass before most States act effectively to meet their obligations to protect the Earth from breaching the 1.5°C temperature cap, or to attain the SDGs. If – as is likely – the 2°C threshold will be breached, States will be under enormous domestic pressure to contain the damage by scrubbing Greenhouse Gases from Earth's atmosphere, seeking to return to a level as close to 1.5°C as possible. 44 This may be a task for three or more future generations. Meanwhile, attaining the “future” guided by the SDGs, as the UN General Assembly still calls for today, will be inevitably postponed. 45 During this lag time in compliance, the mounting harm will inevitably be accompanied by extensive violations of Human Rights. 46
Legal Obligations of States in Respect of Climate Change
The legal road map to the exit ramp can avert this unwanted future. The ICJ's Advisory Opinion on the Obligations of States in Respect of Climate Change is a landmark. 47 Treatises will provide commentary on the Court's profound analysis. The Opinion will guide States throughout the coming years of the climate crisis. This essay provides an initial overview of the Opinion and identifies sectors in which intergovernmental decision-making will initially respond to the Court's rulings.
The Opinion gives the community of nations, and humans across the Earth, and their progeny, 48 certainty regarding rights to a clean, healthy and sustainable environment 49 and clarity to the obligations that each sovereign state owes toward all, erga omnes, for the entire international community. 50 Immediately after this ruling was given on July 23rd it hailed at once alike by those who led negotiations on climate disruption, and by those campaigning for climate change mitigation and adaption. Many jurists at once celebrated the ruling, and their assessments reflect a remarkable unanimity. 51 Christina Voigt welcomed the Court's finding under the Paris Agreement that States’ Nationally Determined Contributions shall reflect the highest possible ambition, and States may not claim that doing so is voluntary or discretionary. 52 Christina Figueres, UNFCCC Executive Secretary (2010–16), said, “this Advisory Opinion gives legal wings to countless efforts already underway—and to many more to come. We now walk forward not just with moral clarity, but with judicial affirmation.” 53 Viewing the video recording of the President of the Court, Judge Iwasawa Yuji, reading the unanimous opinion, is an experience everyone should wish to have, and can. 54
The Court rejected arguments favoring continued reliance on fossil fuels, such as those of the Organization of Petroleum Exporting Counties (OPEC). 55 Parties arguing for treating climate law as a separate body of rules, a lex specialis, that allowed States to make their own decisions about using fossil fuels, failed to win their case. 56 The Court's decision also effectively sets aside past diplomatic maneuvers, in drafting Sustainable Development Goal 13 in 2015, 57 that restricted the UN General Assembly's consideration of climate change in the context of the SDGs. States whose arguments lost have largely declined to comment on the Opinion.
The Advisory Opinion clarifies International Law in four fundamental respects:
First, Earth is “One,” and the Duty to Protect Applies to the Entirety of Earth
All Earth's natural systems are interrelated and States have duties to protect the entirety of Earth. The IPCC documented this reality since 1988, and has shared its peer-reviewed reports with all nations. 58 As authorized by Articles 50 and 62(1) of the ICJ Statute, the Court met with the leaders of the IPCC in November of 2024, before oral arguments. 59 The Court ably reviews applicable climate science. 60
The Opinion addresses each State's conduct for the Earth's entire climate system: “the totality of the atmosphere, hydrosphere, biosphere, and geosphere and their interactions.” 61 This totality is both the accepted scientific 62 and legal 63 definition for the “climate.” Any international law addressed to one part of this all-embracing natural system relates to other parts. When some Parties argued that the treaties should be segregated by sector, and climate agreements being specific should supersede other agreements on biodiversity, desertification, or the marine environment, the Court rejected this line of reasoning. Guided by the 1969 Vienna Convention on the Law of Treaties, 64 the Court read together the environmental agreements with climate treaties. 65 For example, the Court finds that duties under the Biodiversity Convention “are relevant to protection of the climate system, and in particular to the preservation of the biosphere as one of its components, as they are aimed at the conservation and sustainable use of biological diversity, and the prevention of adverse effects thereon.” 66 Obligations relative to climate exist under all environmental treaties. 67 In like vein, the UN Convention on the Law of the Sea (UNCLOS) holds significant climate change duties for States, and the since the discharge of Greenhouse gases is gravely polluting the marine environment, States have a duty to cease such pollution 68 and to cooperate on issues of sea level rise, 69 and the “serious phenomenon” of the loss of homelands for small island states and others. The “duty to cooperate” is not a matter of choice, but a legal obligation. 70
The Court recognized the Human Right to the Environment as a “precondition for the enjoyment of many human rights” 71 that States must take into account in “implementing their obligations” under climate and environmental treaties, and under customary law. 72 The Court acknowledged the references to “harmony with nature” in the Rio Declaration on Environment and Development, 73 but did not examine the later UNGA Resolutions regarding harmony with nature, 74 which have provided the basis for the UNGA's modest deliberations on rights of nature. 75
In 1987, the Brundtland Commission in its report (Our Common Future) stated that “The Earth is one but the world is not.” With the ICJ's Opinion of 2025, the legal world of States, guided by international laws on protecting the one Earth, is also now one. 76
Second, the Stringent Duty of Due Diligence is Mandatory
The Court makes clear that States are obliged under customary International Law to prevent harm to the environment and cooperate with each other in doing so. 77 The Court identified due diligence as the required standard of conduct, that determines if these duties are being met. 78 All available means are to be deployed, including a set of national laws, administrative agencies, and enforcement systems. 79 Where the science is clear, and the threat of harm evident, the “the standard of due diligence will be more demanding for all States.” 80 Given the circumstances of climate change, the Court finds that the “standard of due diligence for preventing significant harm to the climate system is stringent.” 81
Due diligence requires each State to maximize the use of environmental impact assessments (EIA). 82 This is already a customary law duty, and nearly every State has enacted a national law authorizing EIA. EIA also facilitates States in notifying each other and consulting about significant harm to the environment. 83 EIA facilitates a case by case analysis of what may constitute significant harm, and its use will evolve over time. 84 States have the duty under International Law to use their national EIA procedures rigorously. 85
With respect to the duty States have to cooperate with each other, the Court was explicit: “Climate change is a common concern. Co-operation is not a matter of choice for States but is a pressing need and a “legal obligation” 86 to attain “equitable solutions.” 87
Third, International Principles of Law Will Guide States in Differentiated Contexts
The Court recognized that States will apply principles of international law for guiding “the interpretation and application of the most directly relevant legal rules” 88 under treaties and customary law. These principles are (a) sustainable development, (b) common but differentiated responsibilities and respective capabilities (CBDR-RC), (c) equity, (d) intergenerational equity, and (e) the precautionary approach or principle. 89 Scholarly literature extensively evaluates each of these principles. 90 Principles of International Environmental Law, such as equity, have an experiential heritage that enables States to tailor applying stringent due diligence in varied circumstances.
The ICJ examines CBDR-RC at length, finding that all States have the duty to address climate change and the CBDR-RC “cannot justify undue delay or a general exemption from the obligations to exercise due diligence.” 91 The Court did not elaborate on other principles. Some, such as the principle of sustainable development, will require such elaboration.
In her Separate Opinion, Judge Xue Hanqin expands on the principle of sustainable development. She concurs that climate change poses an “unprecedented challenge and threat to all States.” 92 Judge Xue notes that assessing compliance with due diligence duties “needs to applied together with substantive obligations.” 93 To align often disparate States in fulfilling their duties regarding climate challenges, the Principle of sustainable Development can provide unifying motivations. Since 1992, Sustainable Development has been central to all international environmental decision-making. 94 Integrating sustainable development and climate goals will foster the integrated and holistic approach both within each State's “country-driven” context and within a global agenda. 95
Judge Xue's assessment that agreement on the Agenda to attain the SDGs is unifying force that can unite States in “synergy of the global response to climate change and the SDGs.” Considering all SDGs will allow for some variation, as in applying the stringent standard for due diligence to a State's Nationally Determined Commitments (NDCs), in order to accommodate duties to meet the SDGs within each country. 96 Attaining the SDGs is a factor in determining what is the utmost a State can do to meet its duties in respect of climate change. 97 This has implications for international co-operation, including “climate finance and transfer of technology from developed countries.” 98 Others have termed these harmonization considerations as the quest for a “just transition” and “climate justice.” 99
National laws that fulfill the Sustainable Development Goals will be read in pari materia with climate change obligations. Thus, laws protecting biological sinks – such as wetlands – under SDG 15, are a priority also for meeting climate change obligations. Stringent due diligence will require restoring wetlands, to foster ecological resilience. In like vein, national laws mandating “ecological civilization” (ecological restoration, environmental management and “green” development), as in China's Constitution, will be read harmoniously with measures for meeting duties for climate change. 100 Governing under norms of Ecological Civilization, or comparable commitments for attaining the SDGs within a country, 101 might accelerate steps for climate change mitigation and adaptation. As has been noted, “many of the 17 goals are difficult to reconcile,” 102 and thus national climate decisions will need to do so by prioritizing duties of due diligence, and by recourse to applying equity and other Principles.
Fourth, There are Legal Consequences
The breach of either the substantive duties, or the due diligence duties of conduct, constitutes an internationally wrongful act entailing the responsibility of the State. States are under a continuing duty and a breach does not excuse fulfilling the legal obligation. The breach of duties to prevent significant harm to the environment and under climate change treaties and other agreements, are to be “determined by the well-established rules on State Responsibility under customary international law.” 103 These are codified by the International Law Commission. 104 The Court reviews the customary remedies, 105 noting that questions of attribution 106 and causation 107 require concrete factual analysis.
Because the duties are erga omnes, any State may allege a breach on behalf of the international community. 108 Because the harms associated with climate change are many and varied, it is likely that claims of breach will be made in very specific contexts. For example, a State that allows destruction of wetlands and peat, which are sinks for large volumes of GHGs, would be violating both climate duties and biodiversity duties. Rather than seeking compensatory damages, a claim of breach would seek prevention of harm by agreed measures protecting and restoring wetlands and peat. 109 The breach would first be presented for consultation and negotiations to seek cessation of the breach. Mediation or arbitration could be agreed. Meanwhile other plaintiffs could seek remedies under national law in national courts. Failing a settlement, internationally claims could be presented to regional tribunals and international courts with jurisdiction. There are many possible litigation scenarios. 110
The most immediate legal consequence of the ICJ's Advisory Opinion is to provide a legal foundation (a) for States to open negotiations with other States about breaches and (b) for individuals and non-governmental organizations to initiate national and sub-national legal proceeding alleging violations of human rights, of environmental laws and of climate change rules. 111 There will also be recourse to legislative, administrative and judicial authorities to curb and seek to end the extraction, refining, distribution, consumption and economic subsidies for fossil fuels. 112 A State may violate its stringent due diligence duties “by not taking the necessary regulatory and legislative measures to limit the quantity of emissions caused by private actors under its jurisdiction.” 113
Anticipating Future Legal Developments
The ICJ Advisory Opinion will feature in all future international decision-making. Four sectors can be initially noted.
Most important will be action to build the capacity at all levels of government to undertake environmental impact assessments.
122
EIA procedure exist world-wide at national and sub-national levels of government. Most governments give little priority to EIA, considering that is may slow -down development projects. EIA is both fundamental to sustainable development, and to climate mitigation and adaptation. The Court's rulings on EIA position it as central to stringent due diligence.
123
In many States, judicial oversight to enforce EIA procedures will be needed.
IUCN & the ICJ Advisory Opinion
The nearly 100 parties before the ICJ ably presented their interests to the Court. Only one advocated primarily for the natural systems of the Earth: The International Union for the Conservation of Nature (IUCN). When IUCN delivered the final oral argument before the Court on December 13, 2024, 128 IUCN's Director General Grethel Aguilar, an environmental jurist, noted that IUCN is “unique” among the parties. 129 IUCN concurred with the IPCC Sixth Assessment Report. Aguilar welcomed the Court's Opinion as both a “moral and legal imperative.” She stressed that the “the law is not yet moving at the same pace as the escalation of the climate change crisis.” To enable humans to shape our own destinies, she kindly requested “the Court to consider and incorporate our position into its opinion.” Christina Voigt, chair of IUCN's World Commission on Environmental Law, then presented the substance of IUCN's written submissions. 130 All States must do their utmost, with harmonizing all their duties under the Climate treaties and Paris Agreement, the Law of the Sea, and other agreements, and Human Rights. “These are obligations of stringent due diligence.” 131 She articulated the duties under customary International Law, for stringent due diligence.” 132 Her colleague, Francesco Sindico, then reviewed the customary law of State Responsibility. He noted that notwithstanding an unlawful breach, there is always a continuing duty to fulfill the obligations. 133
It is remarkable that IUCN arguments to the Court are aligned substantially with the ICJ Advisory Opinion. IUCN hailed the Opinion. 134 The clarity of the Advisory Opinion has great force. All States need to assess how best to discharge its stringent due diligence obligations. Brazil, host for the COP30 in Belem, has restored a set of stricter climate rules. 135 China welcomed the ruling: “It is of positive significance to maintaining and advancing international climate cooperation.” 136 Because, as the Advisory Opinion makes clear, all international environmental agreements contain duties important in coping with climate change, the rulings of the Advisory Opinion will extend far beyond COP30. It serves little to dwell on the recalcitrance of some States to not at once embrace this Advisory Opinion. Measured diplomatic and legal avenues exist to confront their unlawful conduct. In due course, they will come to prefer cooperation to isolation and suffering. The application of the Advisory Opinion extends well beyond both the 80th Session of the UN General Assembly or COP30. No State today is in full compliance with the legal duties set forth in the Advisory Opinion. 137 States will come to re-dedicate themselves to stringent due diligence. This will take time, but the legal road map is clear.
Conclusion: Lex Lata to Lex Ferenda - The Urgency of Cooperation
The climate crisis propels State and non-State actors alike to reshape international law. The ICJ's Advisory Opinion states the law as it is today, lex lata, but the dynamic, progressive effect of stringent due diligence will drive international law into realizing lex ferenda, the law as it should exist in order for States are to cope with the climate crisis and respect Human Rights. The Opinion upends the legal framework for “business as usual.”
While legal duties for climate change are clear, debates will flourish about how to apply the governing norms. Resolving contested arguments on due diligence will generate renewed cooperation in good faith among States, and indeed among all human institutions. 138 Innovations will emerge from negotiating disputes about how and how quickly a State should adhere to the legal duties set forth in the 2025 ICJ Advisory Opinion. 139 The future will not reflect the past, and the conditions on this road map to the off-ramp are little understood. As today's climate crises become tomorrow's emergencies, the human instinct to cooperate offers hope that wisdom embodied in this Advisory Opinion will prevail.
Footnotes
Funding
The author received no financial support for the research, authorship, and/or publication of this article.
Declaration of Conflicting Interests
The author declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.